ADJ19483679 · May 15, 2026

Applicant was hired in Florida, worked in Florida, and sustained injuries in Florida; no statutory basis for California subject matter jurisdiction exists despite contract law choice of California law and remote supervision from California.

From the decision · page 4On February 9, 2026, the WCJ issued his Finding of Fact, determining that "California does not have subject matter jurisdiction" over applicant's claim. (Finding of Fact, at p. 2.) The Opinion on Decision, issued concurrently, explains that the WCJ's decision was based upon a finding that applicant was hired in Florida, worked in Florida, and sustained her alleged injuries there. (Opinion on Decision, at pp. 5§ 6.) The WCJ noted that the employment contract, while referencing the laws of California, did not reference workers' compensation law. (Id. at pp. 5, 7.)

Applicant was hired in Florida by signing the employment contract and accepting the offer in Florida.

Favours Defendant prevailed

This fact establishes no statutory basis for California subject matter jurisdiction under Labor Code sections 3600.5 and 5305.

From the decision · page 8As to the location of applicant's hire, the parties stipulated that applicant signed the employment contract in Florida. (MOH/SOE, 6/19/2025, at p. 2.) Applicant's testimony at trial makes clear that Aravo offered her employment, and that she accepted that offer of employment while in Florida, by signing the contract. (MOH/SOE, 9/8/2025, at p. 4.) Under binding appellate precedent, the location of hire for the purposes of sections 3600.5(a) and 5305 is the location the offeree accepts the offer of employment. (See Bowen v. Workers' Comp. Appeals Bd. (1999) 73 Cal.App.4th 15, 21-22; Tripplett v. Workers' Comp. Appeals Bd., supra, 25 Cal.App.5th at 565§ 66.)

Applicant worked remotely from Florida and never physically worked or lived in California.

Favours Defendant prevailed

This fact negates the general grant of jurisdiction under Labor Code section 5300 for injuries occurring in California.

From the decision · page 2The matter proceeded to trial, initially on July 9, 2025, with additional trial dates on September 8, 2025 and November 13, 2025. The sole issue listed for trial was statutory subject matter jurisdiction over applicant's claim pursuant to Labor Code1 sections 3600.5 and 5305. (Minutes of Hearing / Summary of Evidence ("MOH/SOE"), 6/19/2025, at p. 2.) The parties stipulated that applicant signed the employment contract in Florida, that applicant resides in Florida, and that applicant did not ever physically work in California. (Ibid.)

Applicant's alleged injury occurred in Florida, not California.

Favours Defendant prevailed

The locus of injury being outside California means no subject matter jurisdiction exists under the statutes.

From the decision · page 8applicant was injured in California, and therefore the argument for general statutory subject matter jurisdiction under section 5300.5 Applicant's alleged injury occurred in Florida, not in California.

Labor Code sections 3600.5, 5300, 5305; King v. WCAB; Johnson v. WCAB; New York Knickerbockers v. WCAB

The WCAB may assert subject matter jurisdiction when there is a significant connection or nexus to California, as governed by Labor Code sections 3600.5, 5300, and 5305, and relevant case law.

The Board applied these standards to determine that no significant connection to California existed because the applicant was hired, worked, and injured in Florida.

From the decision · page 5In general, the Workers' Compensation Appeals Board ("WCAB") may assert its subject matter jurisdiction in a given workers' compensation injury claim when the evidence establishes that an employment related injury, which is the subject matter, has a significant connection or nexus to the state of California. (See § 5300, 5301; King, supra, 270 F.2d at 360; Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson) (2013) 221 Cal.App.4th 1116, 1128.) Whether there is a significant connection or nexus to the State of California is best described as an issue of due process, though it has also been referred to as a question of subject matter jurisdiction. (New York Knickerbockers v. Workers' Comp. Appeals Bd. (Macklin) (2015) 240 Cal.App.4th 1229, 1238; Johnson, supra, 221 Cal.App.4th at 1128.)

Applicant was a remote employee based in Florida and never physically worked in California

From the decision · page 2The matter proceeded to trial, initially on July 9, 2025, with additional trial dates on September 8, 2025 and November 13, 2025. The sole issue listed for trial was statutory subject matter jurisdiction over applicant's claim pursuant to Labor Code1 sections 3600.5 and 5305. (Minutes of Hearing / Summary of Evidence ("MOH/SOE"), 6/19/2025, at p. 2.) The parties stipulated that applicant signed the employment contract in Florida, that applicant resides in Florida, and that applicant did not ever physically work in California. (Ibid.)

Applicant signed employment contract in Florida and accepted offer in Florida

From the decision · page 8As to the location of applicant's hire, the parties stipulated that applicant signed the employment contract in Florida. (MOH/SOE, 6/19/2025, at p. 2.) Applicant's testimony at trial makes clear that Aravo offered her employment, and that she accepted that offer of employment while in Florida, by signing the contract. (MOH/SOE, 9/8/2025, at p. 4.) Under binding appellate precedent, the location of hire for the purposes of sections 3600.5(a) and 5305 is the location the offeree accepts the offer of employment. (See Bowen v. Workers' Comp. Appeals Bd. (1999) 73 Cal.App.4th 15, 21-22; Tripplett v. Workers' Comp. Appeals Bd., supra, 25 Cal.App.5th at 565§ 66.)

Applicant's alleged injury occurred in Florida, not California

From the decision · page 8applicant was injured in California, and therefore the argument for general statutory subject matter jurisdiction under section 5300.5 Applicant's alleged injury occurred in Florida, not in California.